OFAC Compliance Program Template

The five-pillar OFAC compliance program template for payment and agent teams.

How to use

How to use: this template mirrors the five pillars OFAC expects in a compliance program. Fill in the bracketed fields.

The five pillars

  1. Management commitment: senior sign-off and resourcing for [Company] sanctions compliance, reviewed [quarterly].
  2. Risk assessment: product surface (wallets, names, jurisdictions), customer types, and agent autonomy reviewed [annually].
  3. Controls: pre-transaction screening (947 wallets, 19,218 names, 16 jurisdictions), fail-closed behavior, escalation to [Owner].
  4. Testing & audit: independent review of screen logs and controls [quarterly]; full audit [annually].
  5. Training: compliance and engineering teams trained on sanctions obligations [annually].

Why the template exists

OFAC's framework for evaluating compliance programs names exactly these five pillars. A documented program is the difference between a mitigating factor and a finding.

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